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The California Air Resources Board warns that purchasing fuel oil with sulphur content below the regulatory 0.10 per cent limit does not guarantee compliance.

Vessels operating in Californian waters, which is part of the North American ECA, have since 1 January 2014 been required to burn only fuels of distillate grades (marine gas oil or marine diesel oil) with sulphur levels at or below 0.10 per cent. However, following entry into force of the MARPOL ECA Regulation on 1 January 2015, the California Air Resources Board (CARB) has also accepted use of non-distillate low sulphur fuels as an alternative compliance option. This to allow vessels complying with the ECA Regulation to also comply with the California Ocean-Going Vessel (OGV) Fuel Regulation. See CARB’s Marine Notice 2014-1from August 2014.

On 28 October 2015, CARB issued Marine Notice 2015-1 advising that some vessels using non-distillate fuels have been found to violate the OGV Fuel Regulation. On several occasions, shipboard in-use samples collected and tested by CARB staff have been found to exceed the 0.10 per cent regulatory limit even if the corresponding bunker delivery notes lists fuels, as purchased, with a sulphur content below the limit. According to CARB, many of these non-distillate fuels are supplied with a sulphur content very close to the regulatory limit and even marginal admixtures with other higher sulphur fuels could therefore result in the fuel not being compliant. The notice also suggests some possible steps that owners and operators can take to reduce the likelihood of non-compliance, primarily relating to:

  • fuel purchase specifications – source fuel with a sulphur content well below the 0.10 per cent regulatory limit;
  • cleaning of tanks and flushing of supply and transfer lines – avoid mixing with high sulphur fuels; and
  • timing of the fuel change-over operation – operate engines on compliant fuel well before entering regulated waters.

Gard’s Members and clients operating in Californian waters, as well as in the MARPOL ECAs and other regulated areas, should take note of the above and be aware that close attention through training and pre-planning will be required to avoid non-compliance caused by mixing fuels with different sulphur contents.

All marine notices, advisories and alerts for the California OGV Fuel Regulation can be found at: http://www.arb.ca.gov/ports/marinevess/ogv/ogvadvisories.htm. Additional recommended reading: